1. The plaintiff's claim is dismissed.

2. The costs of lawsuit shall be borne by the Plaintiff.

1. Details of the disposition;

A. On July 21, 1986, the Plaintiff did not file a final return on capital gains tax after calculating the amount of tax payable on November 29, 2013 as KRW 240,153,380,000, and subsequently filed a return on capital gains tax after transferring the amount of tax payable on May 31, 2012 to KRW 1,375,50,000 on May 31, 2012 (hereinafter “instant land”). However, the Plaintiff filed a return after calculating the amount of tax payable on November 29, 2013 as KRW 240,153,380, but did not pay the amount of tax. On December 10, 2013, the Plaintiff filed a return on the amount of tax payable as KRW 0.

B. On January 17, 2014, the Defendant issued a payment and notification of capital gains tax of KRW 242,508,350 for the portion without filing a return after the deadline to the Plaintiff, and thereafter confirmed the Plaintiff’s on-site transfer income tax from February 24, 2014 to March 5, 2014. As a result, the portion of the acquisition value excessively appropriated and the portion of the instant land, which did not meet the farmland conditions at the time of transfer, confirmed 1,524 square meters and excluded the reduction and exemption of capital gains tax for the instant portion, and issued an additional disposition to the Plaintiff on May 12, 2014 (including additional tax of KRW 61,818,056) of capital gains tax for the transfer income tax of KRW 113,656,950 for the Plaintiff (hereinafter “instant disposition”).

C. The Plaintiff filed an appeal with the Tax Tribunal on July 24, 2014, but the said appeal was dismissed on December 29, 2014.

[Reasons for Recognition] Unsatisfy, Gap evidence 1, 2, Eul evidence 1 and 2, the purport of the whole pleadings

2. Whether the instant disposition is lawful

A. The Plaintiff’s assertion of this case should be revoked on the grounds that the disposition of this case is unlawful and unjust for the following reasons.

1. The key land in this case was transferred on May 31, 2012 and the officially assessed individual land price in 2012 was also publicly announced on the same day. Pursuant to the principle of non-taxation in the main sentence of Article 157 of the Civil Act, the publicly announced individual land price in 2012 shall take effect on the following day. Thus, the acquisition price of the key land in this case shall be calculated at the conversion price